Basic Federal Income Taxation of Partnerships and S Corporations
Introduces the basic structure for taxing C corporations, partnerships, and S corporations, and reviews several fundamental concepts in dealing with problems in business taxation, such as the Crane rule involving transfers of property subject to liabilities, and the like-kind exchange provision. Most major topics are introduced by a textual discussion of the basic tax factors involved followed by a summary problem that requires reading relevant sections of the Internal Revenue Code of 1986 and Treasury Regulations. Cases, rulings, notes, and problems that deal with more esoteric issues are then presented. The book contains many of the most significant cases and rulings on each major topic.
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Table of Cases
Table of Revenue Rulings and Procedures
10 other sections not shown
adjusted basis apply built-in gain capital account capital gain capital interest Chapter chargeback Commissioner contributed property contributing partner corporate characteristics Crane deduction depreciation determined election entity extent fair market value federal income tax final regulations Frazell gain or loss gross income income or loss interest in partnership Internal Revenue Code issue limited liability company limited partners limited partnership liquidation minimum gain mortgage nonrecourse debt nonrecourse liabilities ordinary income partner's basis partner's distributive share partner's interest partner's share partnership agreement partnership income partnership interest partnership liabilities partnership losses partnership property percent petitioners prior law profits interest proposed regulations pursuant receipt regulations provide result Rev.Rul REVENUE RULING sale or exchange section 721 service partner share of partnership shareholder's shareholders ship special allocation Stafford subchapter substantial economic effect tax consequences Tax Court tax purposes tax shelter taxable income taxpayer tion trade or business transaction transfer treated treatment unrealized receivables